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[Comment-Pso] Name.Space Submission to ICANN and NTIA for Berlin meeting,5-25-27, 1999

To ICANN: The following attached letter is submitted for consideration
at the Berlin Board meeting May 25-27

Esther Dyson
Interim Chairman
Internet Corporation for Assigned
Names and Numbers
339 La Cuesta Drive
Portola Valley, CA 94028

J. Beckwith Burr
Department of Commerce
1401 Constitution Avenue, N.W.
Room 4701
Washington, D.C. 20230


Dear Ms. Dyson and Ms. Burr:

Name.Space, Inc., a Delaware-incorporated Internet Domain Name Registrar, hereby submits this request to ICANN that its unique Top-Level Domains ("TLDs") be added to the root server presently operated by Network Solutions, Inc. ("NSI") under direction of the NTIA and ICANN.

Name.Space understands that, pursuant to Amendment Number 11 to the Cooperative Agreement between the NSF and NSI, NTIA reserves the right to determine whether new TLDs may be added to the root. Further, pursuant to the Memorandum of Understanding between ICANN and NTIA, ICANN will investigate and test the technical and political feasibility of adding new TLDs to the Root. Although Name.Space disputes whether either NTIA or DOC has statutory authority to assert or delegate functions relating to the root, it makes this formal request to ICANN in order to facilitate the process of transitioning the root from the government to the private sector.

I have sent this letter via electronic mail pursuant to the established midnight deadline in order to ensure ICANN's consideration during its forthcoming Board Meeting in Berlin. Hard copy of this letter will follow via first class mail.

Please contact me in writing upon consideration of this request.


Paul Garrin
President, Name.Space, Inc.